Subject: Statements on Bloodborne Pathogens in the Adult Film Industry Cal/OSHA Advisory Meeting

Hello Ms. Gold,

You are very busy and I will keep this to the point. I am a publicist in the adult entertainment industry, and have been working directly in adult, or in cross over situations between the music industry and adult, for almost 20 years. I have been on hundreds or sets, and have spoken to probably a thousand adult performers. What keeps getting lost in arguments concerning blood borne pathogens and how to contain them by using some form of artificial blocking tool is:

The performers in the adult industry do not “have sex” in the way that the general population thinks of when they think of having sex. Adult performers often endure long hours of genital contact with others, with a lot of “stop and start” contact the norm, due to the realities of filming sex. This is far from what most individuals would do in their own home, and that means looking at what an adult performer does as “having sex” is missing the point entirely. Even prostitutes and other sex workers do not have the same reality as an adult performer working in front of a camera. At heart, they are truly professional adult athletes, not “people having sex”, as most people would define it.

Because of this reality, there are common complaints by these adult athletes on the use of condoms. One is that sometimes there is insufficient lubrication present to keep condoms from causing more bodily injury to both parties than not using one would cause. Another is that latex allergies are many times caused by repeated exposure to the material. Just as people can acquire an allergy to wheat or shellfish as they are exposed to it over long periods of time, or for medical practitioners whose exposure to latex can cause allergies to develop, so it is for adult performers and latex in the form of condoms, gloves, or any other device that could be implemented in the course of imposing “safe sex” practices on the adult industry. Sometimes the rush to implement “safety” can be detrimental to the people that AFI Cal/OSHA are indeed trying to protect, as would be the case with steel-toed safety boots for electrical or telephone linemen, so could a blanket proposal to make condoms, dental dams, latex gloves, etc. mandatory for adult performers. Instead of a blanket proposal to make condoms mandatory, shouldn’t it be left to the judgment of the individual performer to decide if they want to use condoms or not?

Further, with the budgets of AFI Cal/OSHA and every other government agency stretched beyond the breaking point at this time, wouldn’t it be in the best interest of AFI Cal/OSHA and the other regulatory agencies involved in this program to continue to support an industry that does enforce self regulation on its OWN dime, than to have to monitor the 5 or more “porn sets” that are actively producing content on any given day in Southern California?

In closing, I would ask that AFI Cal/OSHA keep working in a general oversight position with the adult industry insiders and organizations (such as AIM Medical and the producers and performers, themselves) to monitor the situation concerning the real health issues of these workers and handle them on individual basis, and not to force implementation that may end up with a situation that members of AFI Cal/OSHA never dreamed of happening – putting even more people at risk than they set out to help. Making sure that AIM is doing their job is better suited for the protection of the adult industry performers than mandating health and safety policies that may not work for every individual, or worse, may cause more harm.